A/HRC/32/19 28. For those reasons, the guidance includes a series of recommendations designed to improve the effectiveness of cross-border cooperation between relevant State agencies and judicial bodies, tailored to the contexts of both public law enforcement32 and private law claims.33 C. The need for policy coherence 29. Legal and policy reforms will often have more impact as a package of measures than on their own. Some of the elements in the guidance will depend for their effectiveness on other supporting measures. Awareness of this interconnectedness is needed to avoid the piecemeal development of legal responses for business and human rights issues that has thus far hampered the effectiveness of domestic legal regimes in many jurisdictions. States should strive for both “vertical” and “horizontal” policy coherence in the development of laws and policies that have implications for business and human rights. 34 30. Weak, incoherent or inconsistent regulation not only undermines the effectiveness of legal regimes, but also creates additional barriers to accountability by adding to the costs and complexities of enforcement and creates legal uncertainties and compliance dilemmas for companies. There is room for improvement in the domestic law responses of every State. To support greater policy coherence, the identification of areas for improvement in domestic legal responses may require a formal legal review. To assist States in that regard, OHCHR has developed a model terms of reference for a formal legal review of the effectiveness of domestic legal regimes that may be adapted to respond to local challenges and needs.35 IV. Recommendations 31. Member States should: (a) As part of their implementation of the “Access to remedy” pillar of the Guiding Principles, consider undertaking a review of the coverage and effectiveness of their domestic law regimes that regulate the respect by business enterprises of human rights, using the guidance in the annex to the present report as a starting point, with a view to (i) developing policies and legal reforms that respond more effectively to the practicalities of organization and management of business enterprises and which take into account the particular challenges arising from complex global supply chains; and (ii) improving the effectiveness of State-based judicial mechanisms as a means of delivering corporate accountability and remedy in cases of business-related human rights abuses; (b) Develop a comprehensive strategy for implementation of the guidance in a manner that responds appropriately to local legal structures, challenges and needs, for instance, as part of national action plans on business and human rights, and/or as part of strategies to improve access to justice generally; (c) Take steps, using the guidance, to improve the effectiveness of crossborder cooperation between State agencies and judicial bodies, with respect to both public and private law enforcement of domestic legal regimes. 32 33 34 35 See annex, paras. 9.1-9.7 and 10.1. Ibid., paras. 17.1-17.5 and 18.1-18.2. See principle 8 and commentary of the Guiding Principles. See A/HRC/32/19.Add.1, para. 5. 11